Form 8955-SSA issue with IRS

Has anyone seen this also?

Our firm normally files an extension for both the Form 5500 and Form 8955-SSA at the same time.  We always extend both of them. 

We did that last summer for a 12/31/2019 PYE ESOP.   

We determined later they did not need to file an 8955-SSA so we did not file one.   The Form 5500 was filed timely.  In the past that would have been the end of it.  We however just got forwarded by the client a letter from the IRS informing them the Form 8955-SSA is late.  It should have been filed back on 10/15/2020.  

Is this a new trend?   Do we really have to know by 7/31 if a Form 8955-SSA will be needed or not? 

If someone has gotten this kind of letter before did a simple response saying no form was due enough to satisfy the IRS?

Bumping to top to see if anyone has seen this or not. 

I haven't seen this letter,  but it sounds like the IRS notice generator needs tweaking.  No check boxes or anything on the letter?

I have seen some recent DOL correspondence stating that they have no record of a 2019 Form 5500, requesting a response in 15 days.  

1 hour ago, RatherBeGolfing said:

I haven't seen this letter,  but it sounds like the IRS notice generator needs tweaking.  No check boxes or anything on the letter?

 

There are no boxes on it to say one wasn't required.   It is silent regarding what happens if you do nothing.   It seems like most would say you could get fined if you keep refusing to file.   This one just intimidates the client by implication.  

It doesn't make any sense for them to be that pushy about a filing that might not be required.  Even if you are required to file an 8955-SSA on July 31, 2020, its completely possible for you to no longer be required to file when the extended deadline comes around.  In that case, extending beyond July 31, 2020 and ultimately NOT filing is exactly what you are supposed to do.